Illinois Department of Transportation

October 28, 2002

BUREAU OF DESIGN AND ENVIRONMENT COMMENTS ON
DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY

The Department of Illinois has reviewed and is in agreement with the response provided by AASHTO and provides the additional comments.

Section 1101.2.1 – Referenced Standards, MUTCD

Many of the guidelines supercede or conflict with those in the MUTCD, and for what may be arbitrary causes. If this cannot be avoided, the rational basis for the conflicts should be presented. If the arguments are convincing, the MUTCD should be updated to reflect the changes when accessibility concerns are present.

Section 1101.3 – Defined Terms

The term “blended transition” is used throughout the guidelines, but is never adequately defined. An internet search also yielded no useful definition of the term. Its clear definition should be included in this section. An illustrative figure would also be helpful.

Section 1102.2.2– Alterations
Exception:

The guidelines state that if an alteration with an applicable provision is technically infeasible, the alteration shall comply to the maximum extent feasible. There is not any criteria provided listing what is considered infeasible and who decides and approves what is infeasible. Existing features and limited right-of-way widths could be considered as reasons not to comply with the guidelines. In addition, local communities may coordinate with their disability organizations to better address their constituents’ needs. This may call for variances to these guidelines. Are there any allowances for this?

Section 1102.2.2.2 –Prohibited Reduction in Access
This does not recognize that an accessible route may already be below the requirements new construction.

Section 1102.3 – Scoping Requirements, Alternate Circulation Path

Even if technically feasible, it is not always desirable to provide such an alternate route – particularly along a project’s entire length. In some instances, the project scope and conditions on the ground are such that users cannot or should not be accommodated along the route to be improved for the users’ own safety. Individual jurisdictions should have the flexibility to choose not to provide the alternate path, in consultation with a locality’s disabled community.

Section 1102.5.3- Reduced Vertical Clearance
Define “leading edge” or use better terminology such as “the top” or “the bottom” of guardrail or barrier.





Section 1102.14 – Scoping Requirements, On-Street Parking

The requirement of at least one accessible on-street parking space per block face where on-street parking is provided is arbitrary. This does not consider block length, land use type, density and other pertinent issues. Further, is there a rational basis to believe there is sufficient demand for these spaces? Individual jurisdictions should have the flexibility to craft solutions in consultation with a locality’s disabled community.

There should be a maximum distance between accessible parking spaces to keep travel distance for the disabled to a reasonable level. Based on 1 space per 25 spaces, that would come to about a maximum distance of 660 feet. This somewhat coincides with an informal concept of a city block, about 1/8 mile, and would match roughly to 1 space per 25 where there is continuous on-street parking.

Section 1103.3 – Clear Width

The minimum clear width of 48 inches is an increase from the current IDOT minimum of 36 inches at restrictions. While we do normally provide a clear width of 60 inches, there should be an exception allowed for spot restrictions to 36 inches, such as clearance around utility poles in restrictive right of way.

Section 1104.2 – Curb Ramps and Blended Transitions, Types

What about skewed ramps? Often, the optimal ramp solution is neither parallel nor perpendicular. Again, this appears to be an arbitrary mandate. It would be preferable to allow local jurisdictions the flexibility to craft solutions in consultation with their disabled community.

Section 1104.2.1.1 - Curb Ramps and Blended Transitions, Types, Perpendicular Curb Ramps,
Running Slope

What is the origin of the specified 1:48 minimum running slope? What is the purpose for specifying a minimum slope, in any event – drainage?

Section 1104.2.2.1 – Curb Ramps and Blended Transitions, Types, Parallel Curb Ramps,
Running Slopes

SAME AS DIRECTLY ABOVE.

Section 1104.3.3 - Surfaces

This criteria does not recognize and allow for gratings and access covers and other appurtenances that may already exist in curb ramps, landings, blended transitions, and gutter areas within the pedestrian access. Moving these appurtenances may hinder future maintenance of such items, and significantly complicate drainage and utility design and construction at increased cost.





Section 1104.3.6 – Curb Ramps and Blended Transitions, Common Elements, Counter Slopes

What is the origin of the 1:20 maximum ramp counter slopes? This conflicts with state policy gutter pan slopes (6%), necessary for proper drainage. It could also cause problems in areas of superelevated highway pavement, the slopes of which can be up to 8%.

Section 1105.2.1 - Pedestrian Crossings, Crosswalks, Width

The minimum width is another conflict with MUTCD. What are its origin and justification? If it cannot be avoided, a rational basis for it should be presented. If the basis is valid, the MUTCD should be updated to reflect the changes in areas where there are accessibility concerns.

Section 1105.2.2 – Pedestrian Crossings, Crosswalks, Cross Slope

What is the origin and justification for the 1:48 maximum cross slope? This could greatly complicate intersection design and construction in accessible areas and considerably compromise vehicle ride on the highway facility.

Section 1105.2.3 – Pedestrian Crossings, Crosswalks, Running Slope

What is the origin for the maximum running slope of 1:20? It will be impractical and unsafe in areas of superelevated highway pavement.

Section 1105.3 – Pedestrian Crossings, Pedestrian Signal Phase Timing

What is the origin and justification for the choice of pedestrian walk speed of 3 feet per second? MUTCD calls for 4 feet per second for design. Again, any departure from MUTCD should be supported by rational evidence – at which time the manual should be updated. Individual jurisdictions should have the flexibility to craft solutions for individual locations in consultation with the local disabled community.

Section 1105.4.1 – Pedestrian Crossings, Medians and Pedestrian Refuge Islands, Length

What is the origin of the 72 inch minimum cut-through length? Why is it not 48 inches?
48 inches is what is required for landing areas.

What is the proposed minimum crossing width?
Increasing the minimum length of cut-through in medians from 48” to 72” could be a sole cause for widening. Added width for a median at an intersection would move out the lanes and require associated lane shift tapers. These changes would require removal and replacement of existing curb and gutter, widening, and possibly new right of way, along with new sidewalk in the intersection area. This one change then snowballs into a major intersection modification. This would greatly increase design and construction complexity and cost.”





Section 1105.5.3 Pedestrian Overpasses and Underpasses-Approach
Is the 60 inches in total for a route or a portion thereof? The requirement for an elevator where the rise of a ramped approach exceeds 60 inches seems excessive for a low volume pedestrian route. This guideline does not differentiate between a highly urbanized area with significant pedestrian traffic and a small town with little pedestrian traffic. In addition, if the elevator is unavailable for use due to malfunction, repair, etc. is an alternate accessible route required based on Section 1102.3 of the guidelines?

Section 1105.6.1 – Pedestrian Crossings, Roundabouts, Separation

The requirement for barriers at roundabouts is inconsistent with the treatments used at other locations where pedestrians are prohibited. Positive guidance principles used elsewhere should also be sufficient at roundabouts.

Section 1105.6.2- Pedestrian Crossings, Roundabouts, Signals

The requirement of pedestrian signals at all crosswalks is arbitrary, and potentially onerous. Is there a rational basis to believe there is sufficient demand to justify the signal installations? The potential negative safety and operational impacts on the facility are considerable. Individual jurisdictions should have the flexibility to craft solutions for individual locations in consultation with the local disabled community.

Section 1105.7 – Pedestrian Crossings, Turn Lanes at Intersections

Does this apply to true “slip lanes” where a lane entirely bypasses an intersection, or does it also refer to all turning roadways at intersections? Pertinent literature would seem to indicate it applies mostly to turning roadways. Many of these exist at unsignalized intersections. Is there a rational basis to believe there is sufficient demand to justify these installations? The addition of a signal at each of these locations could have a deleterious effect on vehicular safety and operations. It would also be quite expensive.. Individual jurisdictions should have the flexibility to craft solutions for individual locations in consultation with the local disabled community.

Section 1106.2.1 – Accessible Pedestrian Signal Systems, Pedestrian Signal Devices, Location

What are the origins and justifications for the dimensions shown? In areas where a boulevard two feet (2’) in width exists, meeting the 30” width would not be possible. Individual jurisdictions should have the flexibility to craft solutions for individual locations in consultation with the local disabled community. This guideline does not account for existing accessible routes.

Section 1108.1 – Detectable Warning Surfaces, General

The difficulty of properly clearing these surfaces in snow and ice conditions will render them useless to those they are intended to assist, and will pose undue hazards for all users in such conditions. Allowances should be made for local agencies to continue to coordinate with their disabled population to construct a warning surface pattern that meets the needs of their constituents.



Section 1111.3 – Alternate Circulation Plan, Location

Even if technically feasible, it is not always desirable to provide such an alternate route – particularly along a project’s entire length and on the same side as the existing route. In some instances, the project scope and conditions(i.e., the operation of large equipment) on the ground are such that all users cannot or should not be accommodated along the route to be improved for the users’ own safety. Individual jurisdictions should have the flexibility to choose not to provide the alternate path, in consultation with a locality’s disabled community.

General

A consistent theme of these draft “guidelines” is to establish arbitrary requirements for accessible facilities. This document is very rigid and does not allow for varied degrees of pedestrian use. For this document to serve its intended purpose, any technical requirements therein must be rigorously justified and documented. There must also be rational bases to indicate the need for a specific requirements included therein. There also must be intrinsic flexibility within the guidelines allowing each individual jurisdiction the freedom to create optimal solutions considering all pertinent factors on the ground.

Highway design is currently experiencing a revolution with a concept known as “Context Sensitive Design”, the thrust of which is to tailor designs to the context of their location and users. It seems incongruous to develop accessibility guidelines which are in diametric opposition to this notion, and which cannot result in the best designs obtainable.

There should be a complete set of drawings to depict the various design criteria and concepts.


 

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Comments for AASHTO

IDOT welcomes and endorses the AASHTO comments and recommendations relative to the “Draft Guidelines for Accessible Public Rights-of-Way,” with a few added comments as follows:

1101.2.1 – Referenced Standards, MUTCD.

Many of the guidelines supercede or conflict with those in the MUTCD, and for what may be arbitrary causes. If this cannot be avoided, the rational basis for the conflicts should be presented. If the arguments are convincing, the MUTCD should be updated to reflect the changes when accessibility concerns are present.

1101.03 – Defined Terms

The term “blended transition” is used throughout the guidelines, but is never adequately defined. An internet search also yielded no useful definition of the term. Its clear definition should be included in this section. An illustrative figure would also be helpful

1102.2.2.2 – Prohibited Reduction in Access

This does not recognize that an accessible route may already be below the requirements new construction. Under AASHTO’s recommendation # 2, reference is made to set a maximum cost based on a percentage of the highway construction project. Something being technically feasible or not is not just a cost issue but an impact to the project and also the surrounding area. What about varied degrees of pedestrian traffic? This is not mentioned as a consideration for application of these guidelines. It is a “one size fits all” application.

1102.3-Alternate Circulation Paths
1111.3-Location (of Alternate Circulation Paths)

AASHTO’s recommendation of a minimum time period is a step in the right direction. However, a period of 24 hours or greater or overnight closures is suggested by AASHTO. Should this period either be extended or specific types of operation (work) be permitted without closure, i.e. constructing curb ramps at intersections?

1104.2.1.1 and 1104.2.2.1 – Curb Ramps and Blended Transitions, Types, Perpendicular Curb Ramps, Running Slope AND Curb Ramps and Blended Transitions, Types, Parallel Curb Ramps, Running Slopes

What is the origin of the specified 1:48 minimum running slope? What is the purpose for specifying a minimum slope, in any event – drainage?

1105.4.1 – Pedestrian Crossings, Medians and Pedestrian Refuge Islands. Length

The minimum width is another conflict with MUTCD. What are its origin and justification? If it cannot be avoided, a rational basis for it should be presented. If the basis is valid, the MUTCD should be updated to reflect the changes in areas where there are accessibility concerns. Increasing the minimum length of cut-through in medians from 48” to 72” could be a sole cause for widening. Added width for a median at an intersection would move out the through lanes and require associated lane shift tapers. These changes would require removal and replacement of existing curb and gutter, widening, and possibly new right of way, along with new sidewalk in the intersection area. This one change then snowballs into a major intersection modification. This would greatly increase design and construction complexity and cost.

1108.1 – Detectable Warning Surfaces, General.

The difficulty of properly clearing these surfaces in snow and ice conditions will render them useless to those they are intended to assist, and will pose undue hazards for all users in such conditions. Allowances should be made for local agencies to continue to coordinate with their disabled population to construct a warning surface pattern that meets the needs of their constituents.

General

There needs to be flexibility throughout for transportation agencies to work with local communities to develop solutions that are consistent with local plans.

A full set of illustrations is needed to portray the many numerical criteria and varied designs.

Levels of pedestrian traffic should be considered as a warrant for varied degrees of the application of these guidelines.